Pennsylvania v. Muniz

This decision established the routine booking exception which exempts from the Miranda rule questions designed to gather biographical data from a suspect in order to complete booking.

On 30 November 1986, a patrol officer stopped Inocencio Muniz, who was driving down a Pennsylvania highway. The officer asked Muniz to perform three sobriety tests, which Muniz performed poorly. The officer arrested Muniz and took him to a booking center. At the center the booking procedures were videotaped, as they routinely were. Although the officer told Muniz that his actions and voice were being recorded, Muniz was not read his Miranda rights. Officer Hosterman asked Muniz his name, address, height, weight, eye color, date of birth, and age. Muniz stumbled over his address and age. The officer next asked Muniz the date of his sixth birthday, to which Muniz replied that he did not know. The officer then again administered the sobriety tests that Muniz had performed earlier on the highway. Muniz had difficulty with these tests and attempted to explain his problems. Next, Officer Deyo asked Muniz to take a breathalyzer test, which measures the alcohol content of a person's breath. The officer read Muniz the Commonwealth's Implied Consent Law. Muniz asked questions regarding the law and made comments about his drunkenness. He finally refused to take the test. At this point, the officer read Muniz his Miranda rights. Miranda rights inform a suspect that he has the right to remain silent and that anything said can be used in court as evidence. Muniz signed a statement waiving his rights and admitted that he had been driving drunk.

The video and audio parts of the videotape were used as evidence at Muniz's bench trial, as was the arresting officer's testimony that Muniz failed the roadside sobriety tests and made incriminating remarks. Muniz was convicted of drunk driving. He then filed a motion for a new trial, stating that the court should have excluded the testimony and the videotape because they were completed before Muniz had been read his Miranda rights. The trial court denied the motion, stating that physical tests did not violate his right not to incriminate himself because the evidence from the tests was physical, not testimonial. Therefore, no Miranda warnings were required.

The Superior Court of Pennsylvania reversed this ruling. The court held that when a physical test "begins to yield testimonial and communicative statements . . . the protections afforded by Miranda are invoked. The court stated that Muniz's videotaped confusion and slurred speech indicated his drunkenness. The court noted that Muniz's answer to the question regarding the date of his sixth birthday and the statements he made while performing the physical tests revealed his thought processes. The court believed that none of Muniz's statements were voluntary but were compelled by the questions being asked. Because Muniz made the statements before he received his Miranda warnings, the court felt they should have been excluded as evidence. The court concluded that the audio part of the tape should have been entirely suppressed (not used in court) and reversed Muniz's conviction. The Pennsylvania Supreme Court denied the state's application for review.